Asset management regulatory framework

Compliance

On request, Andbank Asset Management Luxembourg can provide you, with the following policies and procedures free of charge:

• Best Execution Policy
• Complaints Handling Policy
• Conflicts of Interest Policy
• Whistleblowing Policy
• Voting Rights Policy
• Top five execution venues 2018
• Top five execution venues 2019
• Top five execution venues 2020
• Top five execution venues 2021
• Top five execution venues 2022
• Personal Data Protection Notice – AAML

Governance & Remuneration policies

• Disclosure Remuneration
• Sustainability Risk Policy

* AAML does not consider the adverse impacts of its investment decisions on sustainability factors.

* As AAML’s employee count does not exceed 500, AAML is not required to consider principal adverse sustainability impacts on investments.
In addition, due to the inadequate data availability to determine and weight the most important adverse sustainability impacts and indicators as well as outstanding legal provisions, AAML has decided not to take into account the adverse sustainability impacts as defined in Article 4 (1) of the Disclosure Regulation EU 2019/2088 as of March 10, 2021. If the legal provisions are established and the data quality is sufficient, AAML may review the current position and plan any implementation in order to consider the principal adverse sustainability impacts on investments